Abstract

The escalating tit-for-tat between the United States and China over sanctions and counter-sanctions is becoming increasingly pronounced. In the context of intensifying US-Sino strategic competition in recent years, the US government has escalated its use of sanctions as a strategic tool against China. This paper analyses the characteristics of the US economic sanctions regime then delves into the challenges inherent in China's counter-sanction laws and practices. We contend that China should avoid merely emulating the US approach in developing counter-sanction measures. Rather, adherence to principles upheld by WTO rules and other facets of international law should be prioritised. Concurrently, there is scope for reforming the existing framework to enhance its certainty, transparency, and proportionality.